Maynes v. Commonwealth
2012 Ky. LEXIS 20
| Ky. | 2012Background
- Maynes pleaded guilty to reduced third-degree burglary under a diversion and was ordered to pay $130 in court costs at sentencing.
- Maynes argued he could not pay due to unemployment and new fatherhood, and that KRS 31.110 required waiving costs for needy defendants with public defender services.
- Jefferson Circuit Court rejected the arguments; Court of Appeals affirmed, holding KRS 31.110 does not blanketly immunize from KRS 23A.205 costs.
- The dispute centers on how KRS 23A.205 (costs upon conviction) interacts with KRS 31.110 (public defender eligibility) and recoupment provisions in KRS 31.211.
- KRS 23A.205 imposes $100 court costs and requires consideration of present and future ability to pay when not a poor person.
- The Kentucky Supreme Court held that KRS 23A.205 controls over KRS 31.110 in this post-2002 framework and affirmed the Court of Appeals’ decision imposing costs.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Do KRS 23A.205 costs survive indigent defense under KRS 31.110? | Maynes: 31.110 waives costs for needy defendants; Edmonson controls. | Commonwealth: 23A.205 controls; 31.110 not blanket immunity after 2002 reforms. | Yes; 23A.205 controls and costs may be imposed. |
| Is KRS 23A.205 compatible with KRS 31.211 recoupment of costs? | Maynes: costs tied to DPA recoupment should exclude 23A.205. | Commonwealth: 23A.205 costs fall within recoupment framework; both statutes harmonize. | They harmonize; 23A.205 costs are within recoupment scope. |
| Which statute governs ‘court costs upon conviction’ in this context? | Edmonson gives priority to 31.110 over 23A.205. | 23A.205 is the later, more specific statute and controls. | 23A.205 governs costs upon conviction. |
| Does the definition of 'poor person' under 23A.205 create blanket immunity from costs for those eligible for DPA? | If poor person under 23A.205, costs must be waived. | Poor person status may still permit costs to be paid if able in foreseeable future. | No blanket immunity; payment may be required if able to pay in the foreseeable future. |
Key Cases Cited
- Edmonson v. Commonwealth, 725 S.W.2d 595 (Ky. 1987) (treats 31.110 as controlling over pre-23A.205 cost rules)
- Bowling v. Kentucky Dept. of Corrections, 301 S.W.3d 478 (Ky. 2010) (statutory later statute controls in conflict)
- Commonwealth, Dept. of Corrections v. Engle, 302 S.W.3d 60 (Ky. 2010) (reaffirmed modern statutory hierarchy and specificity)
- Wiley v. Commonwealth, 348 S.W.3d 570 (Ky. 2010) (recoupment contexts involving indigent defendants)
- Travis v. Commonwealth, 327 S.W.3d 456 (Ky. 2010) (application of recoupment and indigence principles)
- Ladriere v. Commonwealth, 329 S.W.3d 278 (Ky. 2010) (indigence and costs in post-Edmonson landscape)
- Edmonson v. Commonwealth, 725 S.W.2d 595 (Ky. 1987) (repeated for emphasis on statutory hierarchy)